Head office location alone does not confer jurisdiction if the material cause of action arises elsewhere.

The Petitioner, Samata Party, filed a writ petition seeking to set aside a communication/summons dated December 4, 2025, issued by the Adjudicating Authority, Directorate of Enforcement (ED).

The summons required the Petitioner to provide evidence for an ongoing investigation.

The Petitioner approached the Delhi High Court on the primary ground that the ED’s Head Office is located in New Delhi.

However, the underlying Enforcement Case Information Report (ECIR) and the summons were issued by the Jalandhar Zonal Office in Punjab, and the foundational FIR was registered in Bathinda, Punjab.

1. Whether the Delhi High Court must entertain a writ petition solely because the respondent’s Head Office is situated within its territorial jurisdiction, despite the material cause of action arising elsewhere.

2. Whether the court should exercise its discretion to refuse jurisdiction under the doctrine of forum conveniens.

The Court applied the principles of territorial jurisdiction and the doctrine of forum conveniens.

Indure Pvt. Ltd. v. Government of NCT of Delhi, which establishes that the location of a head office or the passing of an order in the national capital is often "immaterial, non-essential, and non-integral" to a dispute if the "dominant facts" and "legal injury" occurred elsewhere.

Kusum Ingots & Alloys Ltd. v. Union of India, which held that even if a small part of the cause of action arises within a High Court's jurisdiction, the court may refuse to exercise its discretionary power if another forum is more appropriate (forum conveniens).

The Court noted that although the ED's Head Office is in Delhi, the "genesis of the controversy" and the "material, essential and integral" facts—specifically the registration of the FIR in Bathinda and the ECIR and summons in Jalandhar—lie entirely within the State of Punjab.

The Court reasoned that the presence of various authorities' head offices in Delhi does not automatically make the Delhi High Court a "mini-pan-India Superior Court" for all events occurring across the country.

It observed that the act of an authority sitting in Delhi is often a result of the city being the national capital rather than being central to the actual legal injury.

Consequently, the Court found that while a technical part of the cause of action (the head office location) might be in Delhi, the "dominant facts" were situated elsewhere, justifying the invocation of forum conveniens.

It held that the location of the ED Head Office is not the sole determinative factor for jurisdiction when substantial parts of the cause of action arise outside Delhi.

The Petitioner was granted liberty to approach the appropriate jurisdictional High Court (Punjab and Haryana High Court), with all rights and contentions left open.